EMAS in Germany. Report on Experience 1995 to Systematic Environmental Management

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1 Systematic Environmental Management EG-System für das Umweltmanagement und die Umweltbetriebsprüfung Report on Experience 1995 to 1998

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3 Federal Environmental Agency EG-System für das Umweltmanagement und die Umweltbetriebsprüfung Report on Experience 1995 to 1998

4 Imprint: Published and edited by: Federal Environmental Agency Section "Environmental Economic and Social Issues" Bismarckplatz Berlin Germany Tel.: Fax Translated by: The language service of the Federal Ministry for the Environment, Nature Conservation and Nuclear Safety in Umweltbundesamt Berlin 2

5 Contents About this Report... Page 5 FOR READERS IN A HURRY: THE KEY POINTS AT A GLANCE... Systematic Environmental Management Page 7 Page 11 EMAS in Europe Page 13 EMAS and ISO Compared Page Page 18 Purpose, Design and Representative Nature of Survey... Page 21 Number of Employees and Contribution to Turnover... Page 25 Reasons for Participation... Page 29 Cost in Terms of Time... Page 32 Cost in Terms of Manpower Page 34 Financial Cost... Page 35 Cost-Benefit Ratio... Page 37 Environmental Statement: Response and Presentation... Page 41 Assessment of our Guidance Publications... Page 45 Experience with Environmental Verifiers... Page 47 Non-financial Support... Page 48 EMAS: Suggested Improvements EMAS and/or ISO 14001? Page 50 Page 54 Voices from Industry... Page 61 EMAS Survey: Selection of Participants Page 69 3

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7 About this Report In order to permit a better assessment of the situation and prospects of EMAS, the Federal Environmental Agency conducted, during the period from 15 June 1998 to 30 April 1999, a survey of all the German sites registered up to the end of 1998 (1,806 participants). The aspects in the questionnaire included the following: Reasons for taking part Cost-benefit ratio (Was it worth taking part?) Environmental statement (response and presentation) Experience with environmental verifiers Further non-financial support EMAS system (What should be improved?) EMAS and/or ISO 14001? In view of the relatively high response rate of nearly 70 percent, the gratifying representation of the various industries and regions in the sample, and the results of a follow-up survey of non-participants, it may be assumed that the survey results permit a good measure of general application to the survey universe as a whole. The central finding of the survey is as follows: The EMAS system can continue to be a successful instrument of European environmental policy if on the one hand it offers sufficient incentive for voluntary participation (e.g. through greater efforts by the EU Commission and the German government to permanently implant in the public awareness, by means of effective advertising and information campaigns, the Eco Audit idea and the Eco Audit Logo that distinguishes the participating companies), and on the other hand, the environment related requirements for companies and administrative authorities are not set so low as to impair the ecological effectiveness of the regulation system. 5

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9 FOR READERS IN A HURRY: THE KEY POINTS AT A GLANCE Taking responsibility: Systematic Environmental Management In mid 1995 the European Union adopted the Council Regulation (EEC) No. 1836/93 allowing voluntary participation by companies in the industrial sector in a Community Eco-Management and Audit Scheme, usually known for short as the EMAS Regulation. This seeks to induce companies, on a voluntary basis, to develop environmental programmes and environmental management systems, undertake audits and prepare environmental statements. EMAS in Europe: Germany tops the list From the entry into force of the EMAS Regulation in autumn 1995 until 30 June 1995, some 2750 industrial sites were registered in the EU member states. Germany, with 2,085 sites, accounts for about 76 percent of all participants in the EMAS system. It is followed by Austria in second place with 6.9 percent, Sweden in third place with 5.6 percent and Denmark in fourth place with 3.7 percent. A comparison of EMAS and ISO 14001: German preference for EMAS By the end of June 1999, about 11,000 companies worldwide had obtained certification in accordance with the global environmental management standard ISO To date this instrument has been well received in Japan, Germany, the United Kingdom, Sweden and Taiwan in particular. Whereas in Germany there are about one and a half EMAS sites to every ISO certified company, the situation in the other EU member states is very different: here there are more ISO companies than EMAS companies. : steady rise in number of registered sites In Germany the number of registered sites has displayed more or less linear growth since the EMAS Regulation came into force. While only about 40 sites were registered at the end of 1995, the figure rose to nearly 500 by the end of 1996 and around 1000 by the end of In April 1999 the number of registered sites finally topped the 2000 mark. New Länder not out of line At the end of December 1998 there were 288 sites registered in the new Länder (former Eastern Germany). They thus account for about 16 percent of the national total. In terms of the total population of Germany, the new Länder are slightly under-represented. In relation to economic power, however, the new Länder are strongly over-represented. And another comparison: at EU level, the new Länder still come out ahead of all other countries. Workforce: nearly 1.2 million employees In 1995 there were fewer than 60,000 employees working at EMAS sites in Germany. By the end of December 1998 the figure had already reached more than a million. At the end of June 1999 an 7

10 estimated 1.2 million people were working in German EMAS companies. This is about 3.5 percent of the entire gainfully employed population of Germany. Contribution to turnover around DM 125 billion It is possible to make a rough estimate of the annual contribution to turnover made by registered German sites. This indicates that in 1995 the contribution to turnover made by the 60,000 employees at the time was in the region of nearly DM 6 billion. By the end of June 1999 the figure had risen to around DM 125 billion. Widely varying reasons for participation The most important reason given by the companies surveyed for their participation in EMAS was continuous improvement of environmental performance. About three out of four companies see this as an important reason, while only two percent regard it as unimportant. Other important reasons given were: identifying weak spots and potential in the use of energy and resources; motivating employees; greater legal certainty; improvements in organisation; improving corporate image; detecting and minimising environmental and liability risks; and reducing company-specific environmental impacts. Only about half the respondents took part in the EMAS system with the aim of reducing costs. Indeed, for twelve percent this is an unimportant reason. Time factors: environmental management manual, data acquisition and environmental statement In the context of work made necessary by the establishment and development of the EMAS system, the companies surveyed see the following as time consuming or very time consuming (figures in brackets show percentage in agreement): preparing an environmental management manual (78 percent), acquiring data (73 percent), preparing the environmental statement (62 percent), training and informing employees (44 percent), compiling the relevant legal provisions (37 percent), assessing environmental impacts (36 percent). Personnel expenses: at least DM 167 million during start-up phase The sites surveyed estimate that personnel expenses for participation in EMAS average about twelve man months. On the basis of an environmental officer s average gross annual earnings of around DM 80,000, this means the lowest limit for personnel expenses for the 2085 industrial sites registered by the end of June 1999 was at least DM 167 million. Financial cost: at least DM 242 million in the start-up phase The sites surveyed estimate that the financial cost of participation in the EMAS system averages about DM 116,000. Some 40 percent of respondents said that the cost was very difficult to quantify so the information on costs can be no more than a very rough estimate. The total financial cost incurred by German companies as a result of their voluntary participation in the EMAS system from its entry into force until the end of June 1999 is thus estimated to be in the region of DM 242 million. This figure does not include the minimum personnel expenses of around DM 167 million (see above). What benefits has participation brought? At the top of the list of benefits was improved organisation and documentation. Over 80 percent of the companies surveyed stated that this was (fully) applicable. Well over half the registered sites 8

11 succeeded in achieving improvements in legal certainty, corporate image and employee motivation. Further down the list ( partly applicable ) came responsible resource management, site safety, setting an example to suppliers, optimising process workflows, improved cooperation with authorities, positive marketing effects, cost savings and competitive advantages/safeguarding the future of the site. At the tail end of the list ( scarcely applicable ) came cheaper insurance/loans and use of public development funds. Have cost savings been achieved? Around half the companies surveyed stated ( (fully) applicable ) that they had been able to achieve cost savings in the waste sector through their participation in the EMAS system. For nearly 40 percent of the companies this also applied to the energy and water/wastewater sectors. However, three out of four companies said it was difficult to quote an exact figure for the costs saved. Those companies that did quantify their savings put them at around DM 140,000, or DM 330 per employee. Positive or negative cost-benefit ratio? The future success of EMAS is closely linked to the question of whether participation which is after all entirely voluntary ultimately pays off for the company. Twenty-nine percent of the companies surveyed were unable as yet to assess the cost-benefit ratio of participation in the EMAS system. The remaining 71 percent see the cost-benefit ratio as follows: 25 percent positive, 17 percent neutral and 29 percent negative. Environmental statement: response and presentation The interest in the environmental statement displayed by local residents, customers, authorities, media and the general public fell well short of the companies expectations. Equally disappointing from the respondents point of view was the interest displayed by industrial customers, banks and insurance companies, suppliers and employees. A contrasting response is found among scientific institutions, students and business consultants. Here the response was in fact much greater than the companies interest. The quality of the environmental statements varies greatly: on the one hand, as the companies surveyed themselves admitted, there are at least 40 environmental statements that contain no information whatever on relevant environmental effects. On the other hand, there are well over 100 sites today that document environmental indicators which are related to an ecological evaluation procedure. The majority of environmental statements contain a systematic comparison in the form of a substance and energy balance. About 70 percent of the companies surveyed stated that this was (fully) applicable. EMAS: requests for improvements When it comes to the prospects for the future of EMAS, the question of the improvements that the companies surveyed would like to see is a central issue. Among ten suggestions that were put to the companies, better information of the public with regard to the significance and relevance of the EMAS system was clearly given top priority. Second on the list was a more constructive attitude and improved recognition by the authorities, including the exercise of discretion. About 87 percent of the companies surveyed stated that this was (fully) applicable. The larger the industrial site (in terms of employee numbers), the greater the desire for improvement. The aspect of less administrative work by reducing legal measuring and reporting requirements took third place. About 83 percent of the 9

12 companies surveyed stated that this was (fully) applicable. Here too it is noticeable that the bigger the site, the more marked is the desire for improvement. EMAS: relatively large percentage intend to continue In response to the key question Will your company continue participating in EMAS?, the answers were as follows: Yes, preparations already in progress (59 percent), Yes, very probably (29 percent). Here it is particularly noticeable that a much larger proportion of the bigger industrial sites were already tackling the preparatory work for revalidation than the smaller sites. Trump card of EMAS: Continuous improvement of environmental performance What then are the reasons why German companies want to continue participating in the EMAS system? In the first instance it is the continuous improvement of environmental performance. Nearly 90 percent of the companies surveyed said that this criterion (fully) applied to them. In addition, the following features were given particular emphasis by the companies as reasons for continued participation in EMAS: high environmental performance targets, increased legal certainty, strong emphasis on employee participation, preparation of an environmental statement, independent verification. EMAS and ISO 14001: many are taking a dual approach The question of whether the companies were also planning certification under ISO was answered as follows: a good 30 percent already have this additional certification. Nearly 15 percent are planning this additional certification. One in every five companies said that internal discussions were still in progress and they had not yet reached a decision. The rest, in other words about one company in three, have no plans for additional certification. In response to the question concerning reasons for this additional certification under ISO 14001, the criterion of worldwide validity proved to be of overriding importance. There was also widespread agreement with the argument that positive effects can be achieved by combining ISO and EMAS. 10

13 Systematic Environmental Management EMAS Regulation In mid 1995 the European Union adopted the Council Regulation (EEC) No. 1836/93 allowing voluntary participation by companies in the industrial sector in a Community eco-management and audit scheme, usually known for short as the EU Eco Audit Regulation. The core element of this modern piece of environmental legislation is the establishment and development of an industrial environmental management system. Verified environmental management on own responsibility The aim is to induce companies, on a voluntary basis, to develop environmental programmes and environmental management systems, undertake audits and prepare environmental statements. As a reward for their successful participation, sites audited by accredited environmental verifiers and having a valid environmental statement receive (after registration with the competent Chamber of Industry and Commerce) this twelve-star emblem (referred to in the Regulation as statement of participation ): EG-System für das Umweltmanagement und die Umweltbetriebsprüfung This site has an environmental management scheme and its environmental performance is reported on to the public in accordance with the Community eco management and audit scheme. (Registration No....) Enlargement Ordinance In the past the EMAS system was only open to companies in the manufacturing, energy generation, waste management, mining and quarrying industries. However, on 10 February 1998 the Enlargement Ordinance to the EMAS Act (UAG-ErwV of ) entered into force. This now makes it possible to apply the scheme to companies in commerce, service companies and local authorities. 11

14 Town halls discover EMAS too A number of model projects concerning local authority EMASs were initiated prior to the Enlargement Ordinance to the EMAS Act, and their results confirm that it is possible to apply the EMAS Regulation to the public local authority administration. Examples include the model project Communal Eco Audit Baden-Württemberg and the model project Environmental Management of the Municipal Administration of Wuppertal. To provide practical help and guidance for interested authorities, copies of the instructions for these model projects are available: Leitfaden Umweltmanagement für kommunale Verwaltungen, (Guide to Environmental Management for Local Authorities), Landesanstalt für Umweltschutz Baden-Württemberg, Praxisratgeber zur Entwicklung kommunaler Umweltmanagementsysteme (Practical Guide to the Development of Local Authority Environmental Management Systems), Wuppertal Reviews of the projects for introducing an environmental management system in public administration show that in Germany this is done almost without exception in close connection with the EMAS Regulation. Of over 30 projects completed, in progress or planned for integrating environmental protection in public authorities, two thirds are at the local authority level. The local authorities are thus playing a pioneering role in environmental activities in Germany. At the beginning of July 1998 the towns of Isny and Leutkirch were the first towns in Germany to be validated as local authority sites in accordance with the Enlargement Ordinance to the EMAS Act. EMAS itself, as an important step, revealed some extremely interesting findings. Potential for ecological and economic savings became clearly visible. The establishment of an environmental management system has succeeded in organising environmental work and integrating it as a firm component in daily administrative workflows. Revision of the EMAS Regulation (EMAS -II) in preparation The EU Commission is currently proposing to extend the existing scheme under the regulation beyond the present list of industries to take in all areas of business and administration, and to incorporate the international standard ISO in the Regulation. With numerous changes (integration of ISO 14001, enlargement of circle of participants, frequency of environmental statements, inclusion of indirect environmental impacts, more flexible communication, EMAS logo, deregulation, benchmarking), the Commission aims to improve acceptance of the Regulation among potential users and to improve the ecological profile of the Regulation itself. From the German point of view two central objectives for EMAS-II can be identified from experience with the EMAS Regulation to date: Safeguard and strengthen the ecological effectiveness of EMAS Raise its economic effectiveness by incentives to participate. EMAS: the Environmental Management and Audit Scheme 12

15 EMAS in Europe Germany tops the list Between the entry into force of the EMAS Regulation in autumn 1995 and 30 June 1999, some 2,751 industrial sites were registered in the EU member states (Fig. 1). Germany, with 2,085 sites, accounts for about 76 percent of all participants in the EMAS system. It is followed by Austria in second place with 6.9 percent, Sweden in third place with 5.6 percent and Denmark in fourth place with 3.7 percent. Fig. 1: EMAS: How many sites are registered in the member states? Number of registered sites (as at 30 June 1999) Belgien 9 Dänemark 102 Deutschland 2085 Finnland 20 Frankreich 33 Griechenland 1 Großbritannien 70 Irland 7 Italien 18 Luxemburg 1 Niederlande 23 Österreich 189 Portugal 2 Schweden 155 Spanien 36 Source: European Commission Putting it in perspective This picture can be put in perspective by comparing the number of sites in each country with the population or the economic strength of the 13

16 individual EU member state. Using these yardsticks reduces the gaps between Germany and the other EU states, in some cases considerably. In terms of population (Fig. 2) Germany, with 2.55 sites per 100,000 inhabitants is ahead of Austria (2.34 sites), Denmark (1.94 sites) and Sweden (1.74 sites). Well behind are Finland (0.39 sites), Luxembourg (0.24 sites), Ireland (0.19 sites), the Netherlands (0.15 sites) and the United Kingdom (0.12 sites). At the bottom of the list are Belgium (0.09 sites), Spain (0.09 sites), France (0.06 sites), Italy (0.03 sites), Portugal (0.02 sites) and finally Greece (0.01 sites). Fig. 2: EMAS: How does the number of sites registered in the member states relate to their population? Number of registered EU sites per 100,000 inhabitants (as at 30 June 1999) B elgien 0,09 Dänem ark 1,94 Deutschland 2,55 Finnland 0,39 Frankreich Griechenland Groß britannien Irland Italien Luxem burg Niederlande 0,06 0,01 0,12 0,19 0,03 0,24 0,15 Ö s terreic h 2,34 Portugal 0,02 Schweden 1,74 Spanien 0,09 Source: Own calculations, figures from European Commission In terms of economic strength (Fig. 3) Germany, with 0.56 sites per billion DM gross national product, lies only just ahead of Austria (0.52 sites), Sweden (0.39 sites) and Denmark (0.36 sites). These are followed by Finland (0.10 sites), Ireland (0.06 sites), and the Netherlands, Luxembourg and Spain (0.04 sites each). At the back of the field are the United Kingdom (0.03 sites), Belgium (0.02 sites), and France, Italy and Portugal with 0.01 sites each. Greece has only sites per billion DM gross national product. 14

17 Fig. 3: EMAS: How does the number of sites registered in the member states relate to their economic strength? Number of registered EU sites per billion DM gross national product (as at 30 June 1999) Belgium 0.02 Denmark 0.36 Germany 0.56 Finland 0.10 France 0.01 Greece United Kingdom Ireland Italy 0.01 Luxembourg 0.04 Netherlands 0.04 Austria 0.52 Portugal 0.01 Sweden 0.39 Spain 0.04 Source: Own calculations, figures from European Commission

18 EMAS and ISO Compared ISO 14001: Japan ahead of Germany and United Kingdom In order to help businesses to establish and develop environmental management systems, the International Standardization Organization (ISO) has drawn up the worldwide standard ISO Since October 1996, DIN EN ISO Environmental Management Systems Specification with Instructions for Use has had the status of a German standard. By the end of June 1999 some 11,000 businesses worldwide had obtained certification under ISO (Fig. 4). Fig. 4: Environmental management worldwide: businesses certified under ISO Number of businesses certified worldwide under ISO (as at 30 June 1999) Japan Deutschland Großbritannien Schweden Taiwan USA Korea Niederlande Schweiz Dänemark Australien Frankreich Spanien Österreich Finnland Italien Belgien Thailand China (mit Hong Kong) Indien Malaysia Kanada Brasilien Singapur Irland Argentinien Ungarn Mexiko Indonesien Source: Estimate by Federal Environmental Agency To date this instrument has been well received in Japan, Germany and the United Kingdom. In these three countries alone, over 4,600 16

19 businesses have obtained certification under ISO in the past three years. A very positive response can also be seen in the following countries, some with well over 300 ISO companies: Sweden, Taiwan, USA, Korea, Netherlands, Switzerland, Denmark and Australia. German preference for EMAS It is interesting to compare the EMAS statistics with the ISO statistics within the European Union. Whereas in Germany there are about one and a half EMAS sites to every ISO certified company (Fig. 5), the situation in the other EU member states is very different. Example: in the United Kingdom the EMAS system is only of secondary importance compared with the ISO standard: here there is only one EMAS site to fourteen ISO companies. Fig. 5: EMAS / ISO relative proportions within the European Union Number of EMAS sites per certified ISO company in the individual countries (as at 30 June 1999) Belgium 0.07 Denmark Germany Finland France Greece United Kingdom Ireland Italy Luxembourg Netherlands Austria 0.95 Portugal Sweden Spain 0.15 Source: Estimate by Federal Environmental Agency

20 Steady rise in number of sites registered to date In Germany the number of registered sites has displayed more or less linear growth since the EMAS Regulation came into force (Fig. 6). While only about 40 sites were registered at the end of 1995, the figure rose to nearly 500 by the end of 1996 and around 1000 by the end of In April 1999 the number of registered sites finally topped the 2000 mark. By the end of June 1999 there were 2,085 Eco Audit companies registered in Germany. Fig. 6: EMAS: How many sites are registered in Germany? Number of registered sites (as at 30 June 1999) Sep.95 Nov.95 Jan.96 Mar 96 May.96 Jul.96 Sep.96 Nov.96 Jan.97 Mar 97 May.97 Jul.97 Sep.97 Nov.97 Jan.98 Mar 98 May.98 Jul.98 Sep.98 Nov.98 Jan.99 Mar.99 May.99 Source: Own compilation based on figures from DIHT (German Industrial and Trade Association), An average of around 40 registrations per month During the years 1995/1998, an average of about 40 sites a month were registered with the competent chambers of industry and commerce (Fig. 7). The unusually rapid growth in the spring and summer of

21 was probably due to the entry into force in February 1998 of the Enlargement Ordinance to the EMAS Act. For the period up to the end of 1998 the following effect can be observed (figures in brackets are the number of registered sites): Commerce (58), Energy supply (14), Hospitals (13), Transport (13), Hotel and restaurant trade (10), Public administration (8), Wastewater management including other waste management (6), Sports facilities (4), Banking industry (3), Libraries (1), Laundries (1), Test laboratories (1). Fig. 7: EMAS: How many sites are registered in Germany every month? Number of sites registered per month (as at 30 June 1999) Sep 95 Nov 95 Jan 96 Mar 96 Mai 96 Jul 96 Sep 96 Nov 96 Jan 97 Mar 97 Mai 97 Jul 97 Sep 97 Nov 97 Jan 98 Mar 98 Mai 98 Jul 98 Sep 98 Nov 98 Jan 99 Mär 99 Mai 99 Source: Own compilation based on figures from DIHT (German Industrial and Trade Association),

22 Chemical industry, steel and light-metal construction and food industry in the lead The industry statistics for the period to end of December 1998 reveal the following picture (figures in brackets indicate the percentage of the total number of sites registered in Germany): Chemical industry (11.1 percent), Steel and light-metal construction (10.5 percent), Food industry (10.1 percent), Mechanical engineering (7.8 percent), Rubber and plastics (7.1 percent), Motor vehicle manufacture (5.4 percent), Manufacture of furniture/jewellery (5.1 percent), Waste management 7 recycling (5.1 percent), Manufacture of electrical appliances (4.5 percent), Publishing/printing (4.3 percent), Miscellaneous (29.0 percent). About 60 percent of the sites are in North-Rhine/ Westphalia, Bavaria and Baden-Württemberg Broken down by Länder, the figures for the period to the end of December 1998 reveal the following picture (figures in brackets indicate the percentage of the total number of sites registered in Germany): North-Rhine7Westphalia (21.8 percent), Bavaria (21.1 percent), Baden-Württemberg (16.9 percent), Hesse (8 percent), Lower Saxony (5.3 percent), Rhineland-Palatinate (4.7 percent), Saxony (4.4 percent), Saxony-Anhalt (3 percent), Schleswig-Holstein (3 percent), Thuringia (2.9 percent), Berlin (2.6 percent), Brandenburg (1.9 percent), Saarland (1.7 percent), Mecklenburg-Western Pomerania (1.3 percent), Hamburg (0.9 percent), Bremen (0.5 percent). New Länder not out of line At the end of December 1998 there were 288 sites registered in the new Länder (former Eastern Germany). They thus account for about 16 percent of the national total. In terms of the total population of Germany, the new Länder are slightly under-represented. In relation to economic strength, however, the new Länder are strongly overrepresented. And another comparison: at EU level, the new Länder still come out ahead of all other countries. 20

23 Purpose, Design and Representative Nature of Survey Purpose and design of survey In order to permit a better assessment of the situation and prospects of EMAS, the Federal Environmental Agency conducted, during the period from 15 June 1998 to 30 April 1999, a survey of all the German sites registered up to the end of 1998 (1,806 participants): The companies were asked to supply two environmental statements (one copy for building up a database and another for the library). They were also sent an eight-page questionnaire which was developed in close connection with the research findings of the Evaluation Study. Evaluation Study In order to assist the German environmental authorities with the review of EMAS planned for 1998, a 25-strong research group lead-managed by the Institute for Ecology and Business Management (Oestrich-Winkel) was commissioned by the Federal Environment Ministry and the Federal Environmental Agency to carry out what is probably the most comprehensive analysis to date of German environmental management practice. In the context of the UFOPLAN project Evaluation of Environmental Management Systems in Preparation for the 1998 Review of the Community Eco Audit Scheme ( Evaluation Study for short), six different spotlights were used to throw light on the Eco Audit stage from various different angles. Analysis of some 1,600 literary references Investigation of nearly 100 model projects Evaluation of over 200 environmental statements Examination of the legal dimension Empirical investigation of the experience of participating companies Analysis of the experience and expectations of person involved in the procedures and of social pressure groups. The key message of the project is: without a clear and easily explained differentiation of the quality standard between the worldwide environmental management standard ISO and the EMAS system, there is a risk that the EMAS system will be used less and less compared with ISO EMAS should therefore be positioned as Ecological Star Performance. Note Important individual results have already been published by the Federal Environmental Agency in the series TEXTE 20/98 and TEXTE 52/98. The results of the provisional final report are to be published in a book which will probably appear towards the end of The aspects in the questionnaire included the following: Reasons for taking part Cost-benefit ratio Was it worth taking part? Environmental statement: Response and presentation Experience with environmental verifiers Further non-financial support 21

24 EMAS system: What should be improved? EMAS and/or ISO 14001? Return rate nearly 70 percent By the end of April 1999 replies had been received from exactly 1,228 of the 1806 sites written to (45 addresses were unusable). Is a return rate of nearly 70 percent a lot or a little? This result is very gratifying considering that numerous questionnaires had been sent to the registered sites in the past years and months and that the questionnaire was fairly extensive (time and cost factor); rather disappointing considering that all Eco Audit companies have more or less committed themselves to an open dialogue with the public by participating in the Community scheme. Hardly any distortion in sectors and Länder A look at the industry statistics (Table 1) shows only slight discrepancies between the sample and the universe. Take the chemical industry, for example: here the figure for the universe is 11.1 percent and for the sample 11.9 percent. In other words: the chemical industry is only minimally over-represented (0.8 percentage points) in the survey. Table 1 EMAS: How are the various industries represented in the survey? Industry Universe (percent) Sample (percent) Deviation Chemical industry Steel/light-metal construction Food industry Mechanical engineering Manufacture of rubber/plastic products Manufacture of motor vehicles / parts Manufacture of furniture/jewellery/music instruments Waste management/recycling Manufacture of electrical appliances Publishing/printing Miscellaneous * Attribute percentage in sample minus attribute percentage in universe: plus (minus) means that the percentage of the attribute in the survey was too high (low) by the percentage points stated. Source: Federal Environmental Agency A similarly favourable picture emerges from the statistics broken down by Länder (Table 2). The biggest deviation here is found in North- 22

25 Rhine/Westphalia, which is slightly over-represented by 1.3 percentage points. Table 2 EMAS: How are the various Länder represented in the survey? Land Universe Sample Deviation * (percent) (percent) North-Rhine/Westphalia Bavaria Baden-Württemberg Hesse Lower Saxony Rhineland-Palatinate Saxony Saxony-Anhalt Schleswig-Holstein Thuringia Berlin Brandenburg Saarland Mecklenburg-Western Pomerania Hamburg Bremen * Attribute percentage in sample minus attribute percentage in universe: plus (minus) means that the percentage of the attribute in the survey was too high (low) by the percentage points stated. Source: Federal Environmental Agency Follow-up survey of non-participants Do the findings of this report tend to apply also to those companies that did not take part in the Federal Environmental Agency s survey? In order to clarify this question, a follow-up telephone survey was conducted among the non-participants in the survey. Interviews were held with 60 companies chosen at random. The following reasons for non-participation in the survey were found: One company in two did not answer for time reasons alone. In one case in four the questionnaire did not reach the competent officer in time. This deficit, which was observed at large sites in particular, was usually attributed to a transfer of responsibilities. Only in about twelve percent of cases was it clearly stated that the company had expected participation in the EMAS system to bring considerably greater benefits and would therefore no longer be taking part in future. 23

26 Conclusion: the findings of the report are capable of generalisation In view of the relatively high response rate of nearly 70 percent, the gratifying representation of the various industries and regions in the sample, and the results of the follow-up survey of non-participants, we assume that the survey results permit a good measure of general application to the survey universe as a whole. 24

27 Number of Employees and Contribution to Turnover Average of around 590 employees in a German Eco Audit company During the period studied (1995/1998) the average EMAS site in Germany had about 590 employees. The range is considerable: The smallest registered site that took part in the survey by the Federal Environmental Agency was a carpenter s business with three employees. The small business specialises in artisanal furniture production. It is particularly concerned to inform its customers about environmental aspects relating to the handling, use and disposal of the products supplied. The largest registered site that took part in the survey by the Federal Environmental Agency was a car factory with 35,000 employees. In line with the principle We act in an environmentally aware fashion, the company s environmental policy is binding on all employees at the site and is publicised in notices and circulars. Larger companies/sites predominate According to the survey, the majority of the companies taking part in EMAS have more than 500 employees. A statistical analysis of the number of employees in the entire company reveals the following picture: 1 to 99 employees: 29 percent, 100 to 499 employees: 29 percent, over 500 employees: 42 percent. The number of employees at the registered site during the entire observation period 1995/1998 breaks down as follows: 1 to 10 employees: 5 percent, 11 to 50 employees: 14 percent, 51 to 100 employees: 11 percent, 101 to 200 employees: 12 percent, 201 to 500 employees: 20 percent, 501 to 1,000 employees: 13 percent, 1,001 to 5,000 employees: 13 percent, over 5,000 employees: 12 percent. 25

28 Reduction in average size of site In 1995 the average number of employees at the registered sites came to 1,248 persons. The picture for the subsequent years was as follows: 1996: around 1,009 employees, 1997: around 447 employees, and 1998: around 402 employees. Site size and company size developed hand in hand with this trend: Whereas in 1995 the share of larger companies participating (500 or more employees) was still around 75 percent, the corresponding figures for the subsequent years were 52 percent in 1996, 41 percent in 1997 and only 33 percent in Extrapolation: Nearly 1.2 million people are currently employed at the registered sites in Germany In 1995 fewer than 60,000 employees were working at EMAS sites in Germany (Fig. 8). By the end of December 1998 the figure had already reached more than a million. On the basis of 2,085 registered sites for the period to end of June 1999 and the cautious assumption of an average of 400 employees per registered site for the period January to June 1999, it seems likely that nearly 1.2 million people were employed in German Eco Audit companies at the end of June This is about 3.5 percent of the 34 million gainfully employed persons in Germany. 26

29 Fig. 8: EMAS: How have employee numbers developed at registered sites in Germany since autumn 1995? Mitarbeiter Mitarbeiter Mitarbeiter Mitarbeiter Mitarbeiter (bis 30. Juni) Note on extrapolation: The number of employees was determined on the basis of the following estimate: 1995: 47 registered sites x 1,248 employees (average for 1995); 1996: result for 1995 plus 443 registered sites x 1,009 employees (average for 1996); 1997: result for 1996 plus 590 registered sites x 447 employees (average for 1997); 1998: result for 1997 plus 726 registered sites x 402 employees (average for 1998); 1999: result for 1998 plus 279 registered sites x 400 employees (rough estimate for period January to end of June 1999). Source: Federal Environmental Agency Extrapolation: The contribution to turnover made by the registered sites in Germany is currently around DM 125 billion The annual contribution to turnover made by the registered sites in Germany can be roughly determined on the basis of the average sales per employee in the relevant industries (average value added) (Fig. 9). This indicates that in 1995 the contribution to turnover made by the 60,000 employees at the time was in the region of nearly DM 6 billion. By the end of June 1999 the figure had risen to around DM 125 billion. 27

30 Fig. 9: EMAS: What contribution to turnover is made by the registered sites in Germany? 125 Milliarden DM 108 Milliarden DM 78 Milliarden DM 54 Milliarden DM 6 Milliarden DM (bis 30. Juni) Note on extrapolation: The contribution to turnover was roughly estimated on the basis of the average number of employees at the registered site (see Fig. 8) and the average contribution to turnover of an employee in the industries represented in the universe. The relevant turnover figures (gross value added) are taken from the Statistical Yearbook 1998 (base year 1996). Source: Federal Environmental Agency

31 Reasons for Taking Part Widely varying reasons for participation The most important reason the companies surveyed gave for their participation in EMAS was continuous improvement of environmental performance (Fig. 10). About three out of four companies see this as an important reason, while only two percent regard it as unimportant. Fig. 10: EMAS: Why do German companies participate in EMAS? unwichtiges Motiv (0) teils/teils (5) wichtiges Motiv (10) 0 10 Kontinuierliche Verbesserung des betrieblichen Umweltschutzes 8,7 Erkennen von Schwachstellen und Potentialen im Energie-/Ressourceneinsatz 8,3 Motivation der Mitarbeiter 8,3 Imagegewinn 8,0 Erhöhung der Rechtssicherheit 8,0 Verbesserung der Betriebsorganisation 7,8 Aufdeckung und Minimierung von Umwelt- und Haftungsrisiken 7,8 Verringerung unternehmensspezifischer Umweltwirkungen 7,2 Kosteneinsparungen 6,8 Erhöhte Anforderungen von Kunden oder anderen Anspruchsgruppen Entdeckung von ökologischen Produkt- und Verfahrensinnovationen 4,7 4,9 Source: Federal Environmental Agency

32 Other important reasons are: Identifying weaknesses and potentials in the use of energy and resources, Motivating employees, Increasing legal certainty, Improving company organisation, Improving corporate image, Detecting and minimising environmental and liability risks, Reducing company-specific environmental impacts. Cost savings tend to be a secondary reason for participation Only 47 percent of the companies surveyed take part in EMAS in order to save costs. Indeed, for twelve percent this is an unimportant reason. Even less important from the respondents point of view are the aspects increased demands by customers and other demand groups and discovering ecological product and process innovations. Motives are largely independent of employee numbers Hardly any major differences can be found between the reasons for participation and the number of employees at the site. The biggest differences are found for the aspect of image improvement : some 68 percent of the smaller sites (with up to 99 employees) regard this aspect as important, but only 57 percent of the larger sites (with 100 or more employees). Clearer differences between industries There are sometimes appreciable differences in the reasons for participation by the various industries. For example, there are in some cases considerable differences between the chemical industry and the food industry (Table 3): especially with regard to the aspect identifying weaknesses and potentials in the use of energy and resources the difference of 30 percentage points is very large. 30

33 Table 3 EMAS: Reasons for participation by selected industries Reason for participation Continuous improvement of environmental performance Identifying weaknesses and potentials in the use of energy and resources Chemical industry (answer important in percent) Food industry (answer important in percent) Motivating employees Improving corporate image Increasing legal certainty Improving company organisation Detecting and minimising environmental and liability risks Reducing company-specific environmental impacts Cost savings Increased demands by customers or other demand groups Discovering ecological product or process innovations Note on choice of industries: The chemical industry and the food industry are, apart from the steel and light-metal construction industry with a share of ten percent, by far the most strongly represented industries in the universe/sample. Source: Federal Environmental Agency

34 Cost in Terms of Time Average of nearly 14 months The sites surveyed needed an average of about 13.8 months from the decision to take part to registration (Fig. 11). Large and medium sites need considerably more time than smaller sites. Fig. 11: EMAS: How long do sites need from the decision to participate until registration? 13,8 Monate 13,2 Monate 14,8 Monate 14,4 Monate Durchschnitt kleinerer Unternehmensstandort mittlerer Unternehmensstandort größerer Unternehmensstandort Note: small site (1 to 99 employees), medium site (100 to 499 employees), large site (500 or more employees). Source: Federal Environmental Agency Maximum: four years lead time The time from decision to registration differs considerably, according to the respondents: it lies between two and 48 months. The four sites that needed only two months were a carpenter s firm, a bakery, a recycling company and a dairy. The two sites that needed 48 months were a newspaper printing works and a manufacturer of plastic products. Preparation of environmental management manual very time-consuming The environmental management manual serves as an environmental protection guide book for employees. It explains the building blocks of the company s environmental policy, presents the environmental management system, and contains relevant rules and regulations. Nearly 80 percent of the companies surveyed said that it was timeconsuming or very time-consuming to prepare (Fig. 12). Large sites in particular attach special importance to this time factor. 32

35 Fig. 12: EMAS: Time factor Environmental Management Manual The preparation of the Environmental Management Manual was time-consuming or very timeconsuming (agreement in percent) Durchschnitt kleinerer Unternehmensstandort mittlerer Unternehmensstandort größerer Unternehmensstandort Note: small site (1 to 99 employees), medium site (100 to 499 employees), large site (500 or more employees). Source: Federal Environmental Agency Fig. 13: EMAS: Time factor Data Acquisition Time-consuming data acquisition Acquisition of the environment relevant data is also regarded as particularly time-consuming. Nearly three quarters of the companies surveyed said that this was time-consuming or very time-consuming (Fig. 13). Small sites in particular regard data acquisition as disproportionately time-consuming. The task of data acquisition was time-consuming or very time-consuming (agreement in percent) Durchschnitt kleinerer Unternehmensstandort mittlerer Unternehmensstandort größerer Unternehmensstandort Note: small site (1 to 99 employees), medium site (100 to 499 employees), large site (500 or more employees). Source: Federal Environmental Agency Other time factors In the context of work made necessary by the establishment and development of EMAS, the companies surveyed also see the following as time consuming or very time consuming (figures in brackets show percentage in agreement): Preparing the environmental statement (62 percent), Training and informing employees (44 percent), Compiling the relevant legal regulations (37 percent), Assessing environmental impacts (36 percent). 33

36 Cost in Terms of Manpower Average of one man year The sites surveyed estimate that personnel costs for participation in EMAS average about twelve man months. The spectrum is vast: It ranges from one to 250 man months. The correlation between the size of the site and the human resources necessary for participation in EMAS is clear: whereas a small site with fewer than 100 employees estimates an average of seven man months, the information from the companies surveyed indicates that a site with 500 or more employees needs an average of nearly 20 man months. Additional employees taken on? In reply to the question Did you take on additional employees? about one in four respondents replied Yes. The size of the site is virtually immaterial for this question. Extrapolation: Human resources needed for the start-up phase at least DM 167 million The open-ended question In what functions/departments was the cost highest? received the following answers: Environmental protection/environmental officer (28 percent), Production/manufacture/engineering (26 percent), Company management/management (10 percent), Quality management/quality & environmental protection (9 percent), Environmental protection and safety (5 percent), Environmental management officer (4 percent), Safety/safety & environmental protection (2 percent), Miscellaneous (16 percent). On the basis of an environmental officer s average gross annual earnings of around DM 80,000, the lowest limit for personnel expenses for the 2085 industrial sites registered by the end of June 1999 is estimated to be at least DM 167 million. 34

37 Financial Cost Average of DM 116,000 The sites surveyed estimate that the financial cost of participation in EMAS averages about DM 116,000 (Fig. 14). The spectrum is considerable: It runs from DM 5,000 to DM 1,350,000. As expected, there is a clear correlation between size of site and financial cost: Expenditure also increases with the number of employees. Fig. 14: EMAS: How high is the estimated financial cost? Durchschnitt DM kleinerer Unternehmensstandort DM mi ttl erer Unternehmensstandort größerer Unternehmensstandort DM DM Chemische Industrie DM Ernährungsgewerbe DM Note: small site (1 to 99 employees), medium site (100 to 499 employees), large site (500 or more employees). Note on choice of industries: The chemical industry and the food industry are, apart from the steel and light-metal construction industry with a share of ten percent, by far the most strongly represented industries in the universe/sample. Source: Federal Environmental Agency Extrapolation: Financial cost at least DM 242 million in the start-up phase This extrapolation is subject to the following reservation: some 40 percent of respondents said that the cost was very difficult to quantify so the information on costs can be no more than a very rough estimate. The average financial cost per employee is DM 240 per year. The total financial cost incurred by German companies as a result of their voluntary participation in EMAS from its entry into force until the end of June 1999 is thus estimated to be in the region of DM 242 million. This figure does not include the minimum personnel expenses of around DM 167 million (see above). 35